G.R. No. 236807 & 236810, January 12, 2021
Conchita M. Dela Cruz, Petitioner, vs. People of the Philippines, Respondent. / Maximo A. Borje, et al., Petitioners, vs. People of the Philippines, Respondent.

FACTS

Petitioners Conchita M. Dela Cruz (owner of DEB Repair Shop and Parts Supply) and Maximo A. Borje (Chief, Motorpool Section, Bureau of Equipment of DPWH), along with other public officials and a private supplier, were charged with Estafa through Falsification of Documents (Crim. Case No. 28100) and Violation of Section 3(e) of R.A. No. 3019 (Crim. Case No. 28253). The charges stemmed from alleged fictitious transactions for emergency repairs and purchase of spare parts for DPWH vehicles from March to December 2001, amounting to P6,368,364.00. The prosecution presented Disbursement Vouchers (DVs) and supporting documents showing Borje as the payee in numerous transactions and Dela Cruz’s DEB as the supplier. The Sandiganbayan found them guilty beyond reasonable doubt. Petitioners appealed, arguing the prosecution failed to prove conspiracy and their individual participation, and that they merely relied on the regularity of official documents.

ISSUE

Whether the Sandiganbayan erred in finding petitioners guilty beyond reasonable doubt of the crimes charged.

RULING

The Supreme Court DENIED the petitions and AFFIRMED the Sandiganbayan’s Decision. The Court held that all elements of Estafa through Falsification of Public Documents and Violation of Section 3(e) of R.A. No. 3019 were proven beyond reasonable doubt.
1. On Estafa through Falsification: The Court found a conspiracy among the accused. Petitioner Borje, as payee in numerous DVs, and petitioner Dela Cruz, as supplier, participated in a scheme using falsified documents (e.g., Job Orders, Inspection Reports) to justify payments for ghost repairs/purchases, causing damage to the government. Their specific acts, performed in concert with others, established conspiracy. Dela Cruz, as a private individual, was correctly held liable as a co-principal.
2. On Violation of Section 3(e) of R.A. No. 3019: The Court found that the accused public officers, including Borje, acted with evident bad faith or gross inexcusable negligence in approving and processing fictitious transactions. Their actions, in conspiracy with private individuals like Dela Cruz, caused undue injury to the government. Borje’s claim of relying on subordinates’ work was rejected, as his signatures on crucial documents indicated direct participation and accountability.
3. On Credibility of Witnesses and Evidence: The Court upheld the Sandiganbayan’s assessment of witness credibility and the weight of documentary evidence. Petitioners’ defenses of denial and good faith were unsubstantiated and could not prevail over the positive evidence presented by the prosecution.
4. On Penalties: The penalties imposed by the Sandiganbayan were affirmed. For Estafa through Falsification, the penalty was an indeterminate sentence. For the violation of R.A. No. 3019, the penalty was imprisonment and perpetual disqualification from public office.